PRIVACY POLICY

This document explains the privacy policy, the treatment of data, cookies, recommendations, etc…

PRIVACY POLICY

LAST UPDATED: MAY 25, 2018

This Privacy Policy (“PRIVACY POLICY”) explains how SOLARNUB THE SOLAR MARKET INTERFACE, S.L. (hereinafter, “SOLARNUB,” “US,” “OUR,” and “WE”) uses your information and applies to all who use our Web site – SOLARNUB.COM, mobile applications, electronic services, social networking sites, interactive features, online services, or any of our described online activities we own or control (collectively, the “SITE” or “PLATFORM”).

SOLARNUB wishes to inform the users of the site (hereinafter, the “USER” or “USERS”) of our privacy policy regarding the treatment and protection of the personal data of the Users that it collects through the viewing of the website or the use of the services offered through it.

The collection of personal data, the treatment and its subsequent use are subject to the legislation in force in Spain with regard to data protection, in particular Organic Law 15/1999 of 13 December on the Protection of Personal Data (hereinafter referred to as “LOPD”), its implementing regulations or any other legislation that may be applicable.

This Privacy Policy applies only to personal data collected by Houser from the user and that provided thereby through the Website.

This Privacy Statement is incorporated in our Terms of Use, which also apply when you use our Site.

By using the SITE, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with the Site.

GLOSSARY OF TERMS

AFFILIATE means an entity owned, directly or indirectly, by SOLARNUB. or that is controlled by or under common control with SOLARNUB, and also includes joint ventures entered into by SOLARNUB. and/or its Affiliates.

BUSINESS PARTNERS mean, collectively, third parties with whom we conduct business, such as merchants, co-marketers, distributors, and resellers.

COOKIE means a unique identifier, usually made up of small bits of text or code.

DEVICE DATA means information concerning a device you use to access, use, or interact with the Site, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

ONLINE COMMUNITIES mean, collectively, our social networking pages or accounts, forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or linked through the Site.

OTHER PROGRAMS mean special programs, features and functionality on our Site or other co-branded websites with Business Partners that we reasonably control and that have special use terms applicable to such special programs, features and functionality.

OTHER SOURCES mean sources of information that legally provide Agora Intelligence, Inc. with your information, and which are outside the scope of this Privacy Statement at the time of collection.

PERSONAL INFORMATION means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:

CONTACT INFORMATION: your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.

RELATIONSHIP INFORMATION: information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your country, state/province, city, or neighborhood; areas of interest, the types of deals that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); information about persons for whom you have purchased SOLARNUB vouchers as gifts or who have bought SOLARNUB vouchers as gifts for you; and information about friends who refer you or whom you have referred;

TRANSACTION INFORMATION: information you provide when you interact with us and the Site, such as the SOLARNUB vouchers you are interested in, purchase and redeem; email and other communications; and how you interact with Business Partners and our Vendors; and

FINANCIAL INFORMATION: information collected from you as needed to process payments for SOLARNUB vouchers or other products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number.

PIXEL TAGS AND WEB BEACONS means tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.

THIRD-PARTY AD-SERVERS means Vendors and other third parties that provide the technology to place ads on websites and track ad performance.

WHEN ARE PERSONAL DATA COLLECTED FROM USERS ON THE WEBSITE?

SOLARNUB informs its Users that the collection of personal data is carried out, mainly, by sending an email to hello@www.solarnub.com, through the contracts that the User executes with SOLARNUB, as well as through the forms that SOLARNUB makes available to the users on the Website.

In compliance with the provisions of article 5 of the LOPD, we inform you that the personal data that you provide to SOLARNUB will be incorporated into a file that we own and will be processed for the purposes described below.

In addition to the information you provide, we may collect information about your use of our Website in accordance with our Cookie Policy.

SOLARNUB hereby informs the Users of the Website of the optional or obligatory character of filling in the fields marked with an asterisk in the different forms of data collection. In the event that the User does not provide personal data marked as mandatory, you can only view the Website but cannot formalize the contracting of SOLARNUB services.

PURPOSE OF THE COLLECTION AND PROCESSING OF PERSONAL DATA

The personal data collected by e-mail, through the contracts signed by the User with SOLARNUB and/or by completing the forms of the Website will be used by SOLARNUB for the following purposes: to provide the services requested by users; answer user communications; respond to user requests for information; send users the necessary documentation or information requested; manage the contractual relationship; as well as, if we are expressly authorized by the user to do so, send the User commercial and promotional communications related to trading opportunities related to SOLARNUB services, by letter, telephone, email, SMS/MMS or other means of equivalent electronic communications.

Your data may also be used, prior to the anonymization thereof for the segmentation of the data, as well as for the creation of statistics to know the traffic and use of the Website by the users.

Likewise, the data may be used for the determination of your tastes and preferences in order to send promotional information or advertising according to your interests.

DATA ASSIGNMENT

By accepting this data protection policy, you expressly consent that the personal data you provide to us may be transferred to third party companies in the solar sector that are Users of the Platform, for the provision of services related to an opportunity that you would have requested.

Similarly, SOLARNUB hereby informs the User that the data collected here will be transferred to the entity Lemon Way, with registered office in France (number 14, rue de la Beaune, 93,100 Montreuil), which acts as a payment service entity, in order to enable the contracting of the payment service necessary for the use of the Platform.

In this regard, in accordance with the Terms and Conditions, such contracting is necessary to be able to make use of the Platform, for which it is necessary that the User open a payment account with the entity Lemon Way. The User shall maintain a direct contractual relationship with Lemon Way for these purposes in accordance with that set forth in the terms and conditions executed between the User and Lemon Way.

RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION

The User at any time may know which personal data have been collected and processed by SOLARNUB; rectify information that is inaccurate; cancel said data or oppose its treatment.

The exercise of these rights of access, rectification, cancellation and opposition by the User shall be carried out by sending a written communication, together with a photocopy of the National Identity Document or other equivalent means that proves the identity of the User, to the following address: CL. CONCEJAL MUÑOZ CERVAN Nº3 MODULO 5 PLANTA 1, 29007, MÁLAGA. Said communication shall contain the following information:

The User’s full name.

Specific request being made.

Address for the purposes of notifications, date and signature of the User.

Documents evidencing the request, if applicable.

SOLARNUB hereby discloses to the Users that the exercise of these rights is very personal, which is why only the User can exercise such rights with respect to the personal data of which the User is the legitimate owner. However, a legal representative of the User may exercise the rights in the terms set forth, provided that the communication is accompanied by the documentary proof of such representation.

By providing your personal data, the User declares and guarantees that they are accurate, complete, truthful and up to date, saving SOLARNUB harmless of any liability that may arise because of breach of said obligation.

If the User is a minor or legally incompetent, please be advised that you need to have the consent of your parents, guardians or legal representatives for the communication of your personal data, which is why SOLARNUB prohibits minors or legally incompetent persons to provide their data or use the Website without the consent of parents, guardians or legal representatives, and SOLARNUB assumes no liability whatsoever for the actions of minors or legally incompetent persons without said consent.

If you want to deactivate your SOLARNUB account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Site for financial reporting and compliance reasons.

We will retain your Personal Information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes.

SECURITY MEASURES

SOLARNUB has taken all necessary technical and organizational measures to guarantee the security, confidentiality and integrity of the personal data collected, and maintains the levels of security of personal data protection in accordance with the LOPD and its development regulations with the purpose of avoiding any loss, alteration and/or access by unauthorized third parties. SOLARNUB also undertakes to comply with the duty of secrecy and confidentiality regarding the personal data contained in the automated file in accordance with the applicable law.

RECOMMENDATIONS FOR USERS

SOLARNUB recommends that users use the latest versions of computer programs given the incorporation of greater security measures.

SOLARNUB also encourages Users to use the security mechanisms available to them (secure Web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data to the extent necessary.

SOLARNUB reminds users that the Internet is not always safe, so they must take the necessary and appropriate technical measures in order to avoid unauthorized handling of their data.

HOW SOLARNUB USES INFORMATION

We (or our Vendors on our behalf), use information collected as described in this Privacy Statement to:

Operate, maintain and improve the Site and our services, and Other Programs;

Provide you with interest-based ads and offers for products and services from us and participating Business Partners;

Facilitate and fulfill orders placed on the Site and Other Programs – for example, for SOLARNUB vouchers and other goods and services, including tracking redemption;

Evaluate your eligibility for certain types of offers, products or services that may be of interest to you, and analyze advertising effectiveness;

Answer your questions and respond to your requests;

Perform analytics and conduct customer research;

Communicate and provide additional information that may be of interest to you about SOLARNUB. and our Business Partners, sometimes by combining your information with information from Other Sources;

Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of Business Partners;

Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our Business Partners;

Manage our everyday business needs, such as administration of the Site, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with the law;

Allow you to apply for a job, post a video or sign up for special offers from merchants, Business Partners, or third parties through the Site and Other Programs, and to

Enhance other information we have about you directly or from Other Sources to help us better understand you and determine your interests.

We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.

SOCIAL NETWORKS

SOCIAL COMMUNITY AREAS

The Site may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. All the information you post may be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. We recommend that you do not post any Personal Information in the social community areas.

SOCIAL NETWORKS

You may log in to the Site using certain social network credentials. To manage the sharing of certain Personal Information with us when you connect with us through social networking platforms or applications refer to the privacy policy and settings of the social networking website or application.

You also have the option to link social networks, such as Facebook, to your SOLARNUB account. Once you register with SOLARNUB and connect with the social network, you will be able to automatically post recent SOLARNUB activity back to your social network.

By proceeding through any of the above steps, you grant SOLARNUB permission to access all the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Statement.

PRIVACY PRACTICES OF THIRD PARTIES

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

This Privacy Policy only addresses the use and disclosure of information by SOLARNUB through your interaction with the Site. Other websites that may be accessible through links from the Site and Other Programs may have their own privacy statements and personal information collection, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE SPAIN

If you live outside SPAIN, and you use the Site or provide us with Personal Information directly via the Site, your information will be handled in accordance with this Privacy Policy. By using the Site or giving us your Personal Information, you are directly transferring your Personal Information and Non-Identifiable Information to us in the United States. SPAIN may not have the same level of data protection as your jurisdiction. However, you agree and consent to our collection, transfer, and processing of your Personal Information and Non-Identifiable Information in accordance with this Privacy Statement. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Site or provide us with Personal Information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Statement.

CHILDREN’S PRIVACY

SOLARNUB does not intend that any portion of the Site will be accessed or used by children under the age of thirteen, and such use is prohibited. The Site is designed and intended for adults. By using SOLARNUB, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old to create an account and purchase the goods or services advertised through the Site. We will promptly delete information associated with any account be obtain actual knowledge is associated with a registered user who is not at least eighteen years old.

MODIFICATIONS AND UPDATES

SOLARNUB reserves the right to revise this Privacy Policy and the possibility of modifying this Privacy Policy to adapt to applicable legislation and jurisprudence or the criteria or recommendations issued by the Spanish Data Protection Agency. In which case, SOLARNUB will notify the Users by sending an email to the address provided on the Website. All without prejudice to the fact that that Users must regularly check the content of this Privacy Policy.

CONTACT US

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us online at support@solarnub.com.